The window for submitting public comments to Medicare regarding the 2027 Physician Fee Schedule will close on September 14. This deadline is a crucial opportunity for healthcare practices, clinicians, and other stakeholders who wish to influence how their reimbursement rates will be calculated as of January 1, 2027. As of now, there are already more than 44,000 comments on file, highlighting both the importance and the urgency of the issue for the medical community.
Understanding the Context and Importance
The 2027 Physician Fee Schedule proposal is a comprehensive document, spanning 716 pages under file code CMS-1848-P, and was first published in the Federal Register on July 16. The Centers for Medicare & Medicaid Services (CMS) has made it clear that comments must be received by September 14, 2026—merely having your submission postmarked by the deadline is not sufficient. CMS will consider only those comments that actually arrive on time as it formulates and finalizes the new rule.
This comment period is a significant regulatory process, providing stakeholders the opportunity to express their support, concerns, or suggestions regarding the proposed changes to Medicare reimbursement policies. The process is especially vital because the final decisions CMS makes will directly impact the financial health of medical practices and, by extension, the quality and availability of healthcare services for millions of Americans.
What Is at Stake: Key Provisions of the Fee Schedule
At the heart of the proposal is the conversion factor—a number used to calculate Medicare payment rates for physician services. According to the CMS fact sheet, the proposal projects a 1.68% decrease in payments for clinicians who are not qualifying participants in an advanced alternative payment model. For those clinicians who do participate in such models, the projected decrease is 1.19%. This differential is significant, as it could affect practice revenue and potentially influence participation in future payment models.
However, the conversion factor is just the beginning. The proposal contains several additional changes that are equally important and merit careful examination and comment by stakeholders:
- Reduction in payment for separately identifiable office visits billed on the same day as a procedure.
- Rewriting the allocation of indirect practice expenses, which could affect how much practices are reimbursed for overhead costs.
- Capping year-over-year swings in practice expense at 5% to prevent dramatic changes in reimbursement from one year to the next.
- Tightening requirements regarding who can furnish remote monitoring services, which may impact practices offering telehealth or at-home patient monitoring.
- Phasing out traditional MIPS (Merit-based Incentive Payment System) and transitioning to MIPS Value Pathways, which changes how performance is measured and rewarded.
These proposed changes are complex and could have wide-ranging effects on operations, compensation, and care delivery for medical practices. To help practices understand how the new rules will impact their finances, resources such as the 2027 fee schedule handbook and recent articles breaking down the proposal—including ten specific points highlighted by Physicians Practice—are available.
How to File a Comment: The Only Three Accepted Methods
CMS is very clear and specific about how comments must be submitted. There are only three official channels, and every commenter must choose one:
1. Electronic Submission:
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- Go to gov and open docket CMS-2026-2377.
- Follow the guidelines to submit a comment, either by typing directly into the provided box or attaching a file.
- Comments can be submitted as an individual, on behalf of an organization, or anonymously.
2. Regular Mail:
Address your comments to:
Centers for Medicare & Medicaid Services,
Department of Health and Human Services,
Attention: CMS-1848-P
O. Box 8016
Baltimore, MD 21244-8016
3. Express or Overnight Mail:
Use the following address for expedited delivery:
Centers for Medicare & Medicaid Services,
Department of Health and Human Services,
Attention: CMS-1848-P
Mail Stop C4-26-05
7500 Security Blvd.
Baltimore, MD 21244-1850
No matter which method you choose, always reference the file code CMS-1848-P to ensure your comment is properly routed and considered as part of the rulemaking process.
Making Your Comment Count: Tips for Effectiveness
Submitting a comment is only the first step; making sure it’s effective is equally important. CMS discourages duplicate submissions but will still post comments from multiple unique individuals, even if the content is identical or nearly identical. This means signing a form letter organized by a specialty society is not a wasted effort—your voice will still be counted. However, for your comment to have the greatest impact, it is far more compelling and valuable to provide information that CMS does not already possess.
To maximize your comment’s effectiveness:
1. Clearly identify the section of the rule you are addressing.
For example, if you are concerned about changes to remote monitoring services, specify the relevant section and page number if possible.
2. Provide specific, practice-level data and examples.
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- How many same-day evaluation and management visits did your practice bill last year?
- What financial impact does the proposed practice expense rewrite have on your three most frequently used billing codes?
- How many additional staff hours would a new reporting requirement add to your current operations?
3. Use facts and data, not just emotions or general outrage.
Detailed, practice-specific insights can help regulators understand the real-world impact of proposed policy changes. Provide clear facts, relevant data, and specific examples from your practice. Avoid relying only on vague complaints or emotional statements. Well-supported comments are more useful to regulators when they are reviewing the proposed rule and considering possible changes.
Final Thoughts
By submitting a timely and well-documented comment, you can advocate for the needs of your practice. You can also help shape the future of Medicare reimbursement for clinicians across the country. Make sure you follow all CMS submission requirements carefully. Include precise, relevant, and unique data to support your concerns or recommendations. Focus your comments on the provisions that matter most to your practice and the patients you serve. A clear, factual, and well-supported comment can help CMS better understand the potential real-world impact of the proposed changes.
Source: comment-on-medicares